Memorandum Opinion
GOLDBERG, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioner's Federal income taxes for taxable years 1989 and 1990, in the amounts of $4,434 and $2,145, respectively.
The issues for decision are (1) whether petitioner may exclude...
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